Daily living - Activity 6: Dressing and undressing
Activity 6 assesses a claimant’s ability to put on and take off un-adapted clothing that is suitable for the situation. This may include the need for fastenings, such as zips or buttons and considers the ability to put on/take off socks and shoes. As with all the other activities, a claimant is to be assessed as satisfying a descriptor only if they can do so reliably.
Descriptors
The descriptors for Activity 6 are -
- Can dress and undress unaided. 0 points
- Needs to use an aid or appliance to be able to dress or undress. 2 points
- Needs either - (i) prompting to be able to dress, undress or determine appropriate circumstances for remaining clothed; or (ii) prompting or assistance to be able to select appropriate clothing. 2 points
- Needs assistance to be able to dress or undress their lower body. 2 points
- Needs assistance to be able to dress or undress their upper body. 4 points
- Cannot dress or undress at all. 8 points
Source: Part 2 of Schedule 1 to the Social Security (Personal Independence Payment) Regulations 2013 (SI.No.377/2013), andPart 2 of Schedule 1toSR.No.217/2016in Northern Ireland.
NB - in Scotland, adult disability payment is replacing personal independence payment and the descriptors are found inPart 2 of Schedule 1to the Disability Assistance for Working Age People (Scotland) Regulations 2022 (SSI.No.54/2022).
Definitions
Terms used in the PIP descriptors are defined in regulations and, in relation to Activity 6, are -
- “aid or appliance” - (a)means any device which improves, provides or replaces [the claimant's]impaired physical or mental function; and(b)includes a prosthesis;
- “assistance” means physical intervention by another person and does not include speech;
- “dress and undress” includes put on and take off socks and shoes;
- “prompting” means reminding, encouraging or explaining by another person;
- “unaided” means without -(a)the use of an aid or appliance; or(b)supervision, prompting or assistance.
Source: Regulation 2of and Part 1 ofSchedule 1 to the Social Security (Personal Independence Payment) Regulations 2013 (SI.No.377/2013), andregulation 2of andPart 1 of Schedule 1toSR.No.217/2016in Northern Ireland.
See also DWP guidance on Activity 6 in section 2.3 of the Personal Independence Payment assessment guide for assessment providers.
NB - in Scotland, adult disability payment is replacing personal independence payment and the definitions are found inregulation 2ofandPart 1 of Schedule 1to the Disability Assistance for Working Age People (Scotland) Regulations 2022 (SSI.No.54/2022). See also Social Security Scotland guidance inDaily living component activity 6 for ADP -dressing and undressing.
Case law
Commentary: In[2015] UKUT 572 (AAC)Judge Mark ruled that a bed could be an aid for the purposes of getting dressed. However, in[2016] UKUT 197 AAC,Judge Jacobs disagreedfinding that, whilst an item did not have to be specifically designed as an aid, it nevertheless must be sufficiently 'connected' to the activity to count as an aid for the purposes of PIP; in this case sitting on a bed was a common way of getting dressed and it was therefore not an aid.In [2016] UKUT 501 (AAC), Judge Markus prefers the ‘connection argument’, holding that sitting was a ‘usual and normal’ way to dress and that standing was not a necessary function of dressing or undressing.
Suitable alternative clothing may be considered when assessing the functions of dressing, so that slip-on shoes may be acceptable for someone who cannot bend to do up laces [2016] UKUT 542 (AAC), or a cardigan for someone who cannot raise their arms to put on a pullover [2016] UKUT 309 (AAC) (reported as [2016] AACR 10). However, Judge Jacobs in the latter case warns that tribunals should not define away multiple functional problems by identifying multiple alternatives - which would result in a claimant only being assessed to wear loose elasticated clothing with no fastenings - as this would restrict the functional test to only part of the activity of dressing. |Add commentary or suggest an edit.
- Assistance needed to put on prescribed compression stockings counted for purposes of ‘managing therapy’ activity but not for purposes of ‘dressing and undressing’ activity
- [2024] UKUT 244 (AAC)
- UA-2024-000104-PIP
- CF v Secretary of State for Work and Pensions
- Dressing and undressing
- Engaging with other people face to face
- Managing therapy or monitoring a health condition
- Crutches as an aid for dressing or undressing if reasonably required by claimant who needs to stand to complete activity
- [2019] UKUT 293 (AAC)
- CPIP/285/2019
- MR v Secretary of State for Work and Pensions (PIP)
- Aids and appliances
- Dressing and undressing
- Extra time choosing clothes on the basis of appearance can be relevant to the test for daily living activity 6
- [2017] UKUT 171 (AAC)
- CPIP/3760/2016
- ML v Secretary of State for Work and Pensions (PIP)
- Anxiety and depression
- Dressing and undressing
- Eating disorder
- Obsessive compulsive disorder
- Reliably
- Choosing clean clothes and dressing to an acceptable standard / impulsive spending may satisfy descriptor for making complex budgeting decisions
- [2017] UKUT 156 (AAC)
- CPIP/3730/2016
- DP v Secretary of State for Work and Pensions (PIP)
- ADHD
- Dressing and undressing
- Making budgeting decisions
- Reliably
- Need for aid or appliance to either dress or undress is sufficient for descriptor 6b / ability to put on slip-on shoes but not shoes with fastenings does not score points
- [2016] UKUT 542 (AAC)
- CPIP/772/2016
- JM v Secretary of State for Work and Pensions (PIP)
- Dizziness
- Dressing and undressing
- A bed is unlikely to amount to an aid for dressing and undressing / mobility descriptor 2(c) and ability to walk more than 50 metres with walking aids
- [2016] UKUT 501 (AAC)
- CPIP/3352/2015
- AP v Secretary of State for Work and Pensions (PIP)
- Aids and appliances
- Dressing and undressing
- Moving around
- An aid normally used by a person with no disability is only an ‘aid’ for the purposes of the PIP descriptors if sufficiently ‘connected’ to the relevant activity
- [2016] UKUT 197 (AAC)
- Reported as [2016] AACR 44
- CPIP/3369/2015
- CW v Secretary of State for Work and Pensions
- Aids and appliances
- Arthritis and joint pain
- Dressing and undressing
- Claimant may be able to establish a need for prompting even if able to perform a specific task when there is impetus to do so
- [2016] UKUT 194 (AAC)
- CPIP/181/2016
- GG v Secretary of State for Work and Pensions (PIP)
- Anxiety and depression
- Dressing and undressing
- Engaging with other people face to face
- Fluctuating conditions
- Preparing food
- Substance misuse
- Washing and bathing
- Use of microwave to heat ready prepared food is not sufficient / Importance of applying regulations 4 and 7
- [2016] UKUT 150 (AAC)
- CPIP/1418/2015
- LC v Secretary of State for Work and Pensions (PIP)
- Dressing and undressing
- Fluctuating conditions
- Preparing food
- Reliably
- An ordinary chair or bed can constitute an ‘aid’ for the purposes of the PIP descriptors if a claimant needs to sit on it to dress or undress
- [2015] UKUT 572 (AAC)
- CPIP/2168/2015
- NA v Secretary of State for Work and Pensions
- Aids and appliances
- Back and neck pain
- Dressing and undressing
- Fatigue
- Relevance of type of clothing to activity 6 (dressing and undressing) / Application of regulation 4(2A)
- [2015] UKUT 309 (AAC)
- Reported as [2016] AACR 10
- UK/5338/2014
- PE v Secretary of State for Work and Pensions
- Dressing and undressing